Additional compensation under Section 30(3) must be computed on market value including the multiplication factor.

The petitioners are landowners whose lands were acquired under the National Highways Act, 1956. An award was passed on 23.08.2017 calculating the market value by applying a multiplication factor of 2.

However, when granting the 12% additional compensation under Section 30(3) of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 ("2013 Act"), the authority only used the "base market value" (pre-multiplication) instead of the total market value derived after applying the multiplication factor.

The petitioners approached the High Court seeking the deficit in additional compensation, interest under Section 80, and benefits under the Second and Third Schedules of the 2013 Act.

1. Whether the additional compensation of 12% under Section 30(3) of the 2013 Act should be computed on the market value after applying the multiplication factor 2 as provided under Section 26(2).

2. Whether the petitioners are entitled to statutory interest under Section 80 of the 2013 Act on the unpaid portion of additional compensation.

3. Whether the petitioners are entitled to Rehabilitation and Resettlement benefits under the Second and Third Schedules of the 2013 Act despite the delay in filing the petition.

The court applied Section 26 and Section 30(3) of the 2013 Act, interpreting "market value" as the final value determined after applying the multiplication factor prescribed in the First Schedule.

It relied on the definition of "market value" in Section 3(u) and the principles of statutory interpretation that the same expression must bear the same meaning throughout the statute.

The court followed the precedent of Union of India v. Tarsem Singh [(2019) 9 SCC 304] and NHAI v. P. Nagaraju [(2022) 15 SCC 1], which extended 2013 Act benefits to National Highway acquisitions.

It also applied Section 80 of the 2013 Act regarding interest on unpaid compensation.

The Court reasoned that "market value" under Section 26 is the end product of all components, including the multiplication factor for rural areas under Section 26(2). Thus, the adjective "such" in Section 30(3) refers to this total computed value, not merely the base value under Section 26(1).

To hold otherwise would ignore the legislative intent to compensate for inflation during the pendency of proceedings.

Regarding interest, the Court held that since the full compensation was not paid at the time of the award, interest under Section 80 is mandatory, though limited to three years due to the petitioners' delay in approaching the court.

However, claims for Rehabilitation and Resettlement (Schedules II and III) were denied based on the principles of estoppel and acquiescence, as the petitioners failed to raise these claims during the 2015-2016 acquisition process.

The Court directed the payment of statutory interest under Section 80 at 9% and 15% for a period of three years from the date of the award. The prayers for benefits under the Second and Third Schedules were rejected due to delay and laches. The Competent Authority was directed to pass the modified award within six weeks.